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Decision on the European Investment Bank’s response to concerns about it holding certain personal information of job applicants before recruitment decisions

The case concerned a practice of the European Investment Bank (EIB) of asking job applicants to provide certain personal information, notably related to their family situation, before the EIB’s recruitment decision.

The Ombudsman recognised that the EIB had established this practice to make its procedures as efficient as possible. However, she expressed concern that the gathering of personal information was disproportionate and could negatively impact on trust in the EIB’s recruitment procedures. Not all applicants would necessarily be reassured that the personal information would under no circumstances play a role in their chances of getting the post.

The EIB replied that it had changed its practices to address the concerns raised by the Ombudsman.

The Ombudsman welcomed the EIB’s constructive response, and closed the inquiry.

The inquiry

1. The Ombudsman set out the issue in her letter opening the inquiry: the EIB had established a practice whereby it requests certain personal information (such as on household composition and dependants) from job applicants. This practice was related to efficiency concerns. She noted that the EIB had in the meantime changed this practice to make the provision of such information voluntary. This may nonetheless be problematic in practice. If candidates are asked to provide information in the context of a recruitment procedure, they may consider that failing to do so could negatively prejudice their prospects[1].

2. The EIB replied that it had reconsidered its practice and decided not to ask candidates for any information regarding their family situation, including information on dependents - not even on a voluntary basis - before the final candidate is determined. This new procedure is in place since 1 April 2021. As a consequence, applicants are no longer asked to provide information on their family situation during the selection process. Only the selected candidate (i.e. for whom a signed selection note has been sent to Personnel) is asked to provide the personal details regarding their family situation to determine their benefits package. The changes have been formalized in the internal procedures of the EIB[2].

3. The Ombudsman very much welcomes the EIB’s response in this case.


The Ombudsman closes the inquiry with the conclusion that the EIB has given a most constructive response and that the matter is now settled.

Emily O'Reilly
European Ombudsman

Strasbourg, 01/12/2021


[1] The Ombudsman’s full letter is here: https://www.ombudsman.europa.eu/en/doc/correspondence/en/143366

[2] The EIB’s full reply is here: https://www.ombudsman.europa.eu/en/doc/correspondence/en/149856